The BC government recently called for comments on the re-opening of two areas of the grizzly bear hunt in our province. To voice our opinion on the matter, we sent in our position to the Ministry of Forest, Lands and Range Operations. See below for our full comment. For more information, please contact us.
Director Resource Management – Cariboo
Ministry of Forest, Lands and Range Operations
Williams Lake, BC
December 20, 2013
RE: Proposal #1158 - to open grizzly bear hunting in Management Units 5-05 and 5-06
Dear Mr. Stewart,
As mentioned in a voicemail message to you just now, I am emailing your our comments as the website appears to be already closed for comments even though it states that the closing date for comments is December 20.
The Coast to Cascades Grizzly Bear Initiative represents organizations that have a variety of perspectives on grizzly bear hunting in BC (www.coasttocascades.org). Our Initiative is not engaged in the larger issue of grizzly bear hunting in the province.
Our comments on grizzly bear hunting in Units 5-05 and 5-06 of the Kliniklini-Homathko grizzly bear population unit reflect the explicit focus of the Coast to Cascades Grizzly Bear Initiative: to ensure the recovery of grizzly bears in southwest British Columbia’s five threatened grizzly bear population units (GBPUs). These include Garibaldi-Pitt (3 bears), North-Cascades (6 bears), Stein-Nahatlatch (24 bears), Squamish-Lillooet (59 bears), and South Chilcotin Ranges (203 bears) (BC Government, 2012).
Recovery of southwest BC’s threatened GBPUs almost certainly requires long-term management of adjacent population units consistent with regional recovery direction and the maintenance and/or restoration of meta-population dynamics. Without such an approach, recovery of threatened GBPUs will be difficult at best, unachievable at worst. Moreover, considering recovery of threatened populations in this context is potentially one cost-effective insurance policy against continuing declines of the threatened GBPUs and ultimately toward population recovery. And given the precipitously low populations of some GBPUs, the sooner that grizzly bears from viable populations expand south the better the chances of recovery are.
Although its population is still depressed, the South Chilcotin Ranges GBPU has the largest population of southwest BC’s five threatened GBPUs. However with 13 animals per 1000 sq. km (BC Government, 2012), grizzly bear densities in the GBPU are considered low (Nielson, 2011).
Nonetheless recovery of the other four threatened GBPUs to the south depends in large part on the South Chilcotin Ranges GBPU as a source population and a pivotal link in a regional grizzly bear meta-population insofar as it is located between the “threatened” units and nearest two “viable” grizzly bear population units.
Government biologists estimate the four southernmost GBPUs have fewer than a combined total of 100 animals. Because grizzly bears are extirpated to the east and south of these four GBPUs it is reasonable to assume that the Toba-Bute and Kliniklini-Homathko populations, and as it recovers the South Chilcotin population will be the most important sources of bears for more southerly threatened populations.
It is very important to the recovery of southwest BC’s five threatened GBPUs that the Klinaklini-Homathko’s population level is allowed to grow and expand consistent with habitat suitability and that it can play an appropriate role in regional grizzly bear recovery. Government has an obligation to help achieve healthy, well-distributed grizzly bear populations consistent with natural carrying capacity of the each population unit across the landscape.
In other words, there has to be a priority put on ensuring that resident grizzly bear density in Klinaklini-Homathko is robust enough that over time sufficient numbers of grizzly bears can disperse into the South Chilcotin GBPU and beyond. The striking success of grizzly bear recovery efforts in US Yellowstone and the Northern Continental Divide Ecosystems was predicated on stopping human caused mortality in core habitats to promote dispersal outward. The likelihood of duplicating those successes for southwest BC’s threatened GBPUs falls seriously into question if there is legal hunting on top of the current background mortality in source populations like Klinaklini-Homathko.
Grizzly bears reproduce very slowly and thus their populations expand very slowly. Female grizzly bears rarely disperse very far from their mother’s home range. Such factors mean that grizzly bear source populations must grow steadily to cause the outward expansion into areas of lower density. Hunting source populations diminishes the need for those populations to expand geographically.
Finally, given the status of adjacent GBPUs and gaps in research regarding bear movements among all the relevant GBPUs, there should be a high level of confidence in the methodology used to estimate grizzly bear numbers in Klinaklini-Homathko GBPU . Grizzly bear density estimates in the Kliniklini-Homathko GBPU are similar to those in the South Chilcotin GBPU yet one is considered “viable” and one is considered “threatened”. Our groups would like to understand the metrics used to inform these classifications including existing and foreseeable threats and population and habitat trends.
Concerns regarding data and methodology:
1. Lack of credible data on which to base the decision to reopen the hunt. We are unaware of any recent field efforts in MU’s 5-05 and 5-06 that provide credible data to support a new population estimate on which to reopen the hunt. If the biologists in the Ministry of Forest, Lands and Natural Resource Operations have data to support the new population estimate that information should be made public (and the comment period extended). If that data is lacking, it brings into question the province’s commitment to … “scientifically ”… manage the grizzly bear hunt. Furthermore, in the case that sufficient empirical data does exist, government staff recommending the reopening of the hunt in MU’s 5-05 and 5-06 should share their methodology and rationale.
2. Lack of evidence that unreported, illegal and conflict kills have been reduced; inconsistent criteria for determining hunt reopening. Grizzly bear hunting in Management Units 5-05 and 5-06 was closed in 2000 in response to human caused mortality exceeding allowable limits (we assume based on 1999 data of 4 deaths and a 26 year average of 2 bears per year). Government is now proposing to reopen a limited entry hunt with a 5 bear limit on top of what may very likely be an overkill situation in the GBPU equivalent to or higher than accepted in 2000.
We are not aware of any significant efforts to reduce or eliminate non-hunting human-caused grizzly bear mortality in these MU’s and thus conclude that unreported grizzly bear mortalities continue to exceed acceptable limits.
We are concerned in fact that changing circumstances in the last 13 years (e.g. increases in roaded access for pine beetle salvage logging) may have actually worsened the situation and should be taken into consideration when determining unreported mortalities. Reopening the hunt without better data on/investigation into, and mitigation of human-caused grizzly bear mortality (such as a threats analysis) is not defensible.
3. An over-reliance on anecdotal evidence. We are concerned that anecdotal evidence indicating there are more bears in 5-05 and 5-06 was used as justification to reopen the hunt in those units. Anecdotal reports can be useful additions to science-based management, but should not underpin or substitute for it (McKelvey et al. 2008).
4. Low confidence in the usefulness of fall observations by DFO staff along the Chilko River. The grizzly bear hunt has been closed in MU’s 5-05 and 5-06 for approximately 13 years. It is possible that in the intervening years at least some of those bears have grown more comfortable in the presence of humans and thus have become more visible, particularly during summer and fall salmon seasons. It is quite possible that increased bear visibility is being conflated with higher bear numbers.
Based on the extensive concerns listed above, the Coast to Cascades Grizzly Bear Initiative opposes the reopening of a grizzly bear hunt in MUs 5-05 and 5-06 at this time.
Field Director, Coast to Cascades Grizzly Bear Initiative
Nielson, Scott. Relationships between grizzly bear source-sink habitats and prioritized biodiversity sites in Central British Columbia. Research Report BC Journal of Ecosystems and Management, 2011
Government of British Columbia, Ministry of Environment website; Environmental Reporting BC; Grizzly Bear Population Status, 2012 http://www.env.gov.bc.ca/soe/indicators/plants-and-animals/grizzly-bears.html?WT.ac=LU_Grizzly-status
McKelvey, Kevin et al. Using Anecdotal Occurrence Data for Rare or Elusive Species: The Illusion of Reality and a Call for Evidentiary Standards.